Corporate Principles
EthicsCode of Conduct
Purpose of the Code of Conduct
The Code of Conduct contains the binding standards and the expectations weplace on our day-to-day behavior to achieve ethical business conduct.
These principles are binding upon all board members, managing directors, executives and employees worldwide. Executives in particular are expected to set a
good example.

01 In our dealings with our customers, business partners, employees and owners,
General Principles

we undertake to act fairly and with integrity at all times.

We offer our customers travel and logistics services which are safe, environmentally and socially responsible and cost-effective.
Our purpose of pursuing our business activities in accordance with ethical andlegally irreproachable principles is inextricably linked with the way in which we
behave at our work. In all our business activities we abide by the applicable laws
and, on this basis, respect the individual cultures of the countries in which weoperate.
We expect and encourage our business partners to introduce similar ethical principles themselves on the basis of applicable laws and accepted values. We expect them to comply with the principles laid down in the DB Code of Conduct for
Business Partners, which is derived from the Corporate Principles on Ethics, inour business dealings and to make compliance with them mandatory for suppliers in their supply chain.

02 We are convinced that economic, social and environmental dimensions must
Corporate Social and Environmental Responsibility

be brought into lasting harmony in order to ensure sustainable corporate success and social acceptance. Creating this harmony is consequently an indispensable element of our value-driven corporate management. All corporate
activities are therefore bound by our obligation to be a good corporate citizen.
Customer satisfaction and product quality as well as profitable growth areconsequently factors of equal importance to the success of the DB Group as
cultural change, employee satisfaction and resource conservation as well as
the reduction of emissions and noise.
Within the scope of its business activity, the DB Group complies with the internationally recognized human rights and fundamental freedoms in accordance with its Policy Statement and the principles set out in the International
Human Rights Charter 1 as well as the ILO Declaration on Fundamental Principles and Rights at Work 2 as set out below. The DB Group has committed tothe Ten Principles of the UN Global Compact. We are also guided by the UN
Guiding Principles on Business and Human Rights (UNGP) and the OECD
Guidelines for Multinational Enterprises.

Human Rights

We help to protect and promote the principles of internationally recognizedhuman rights through our actions, as far as doing so does not violate locallaws.
We reject prohibited forms of child labor and any form of forced labor or modern slavery.

Child Labor,Forced Labor andModern Slavery

The employees of the DB Group reflect the diversity of society, languages,cultures and lifestyles. We respect and promote this diversity, as it is the guarantee of our closeness to society, to our customers, and our openness to newideas.

Equal Opportunities/Diversity

We do not tolerate sexual harassment or discrimination against individuals, inparticular due to their national, ethnic or social origin, color, health status, disability, sexual orientation, gender, age, political opinion, religion, or belief ormembership in a trade union. This principle of non-discrimination also extends
to remuneration.
Remuneration

We pay our employees and those who work on our behalf a compensationthat is appropriate and in accordance with applicable laws and collectively
bargained agreements.

Cooperation

Our cooperation and dealings with one another are defined by mutual respect.
We behave cooperatively and ensure a positive working environment.
Our employees play a vital role in determining the success of the DB Group.
The DB Group acknowledges its responsibility to all employees, to support
them and encourage their ongoing development.

1
Consisting of the United Nations Universal Declaration of Human Rights (UDHR) as well as the Civil
Pact (International Covenant on Civil and Political Rights, ICCPR) and the Social Pact (InternationalCovenant on Economic, Social and Cultural Rights, ICESCR).
2ILO Conventions 29, 87, 98, 100, 105, 111, 138, 155, 182.

Freedom of Association

The DB Group respects the rights of employees and people who work on ourbehalf to freedom of association and the right to form legally protected organizations.

SafetyPutting the safety of our employees, of people who work on our behalf and of
our customers first is at the core of the Group's values. Together, we ensurea safe working environment and the safety of our products.

Occupational Health

By means of systematic preventative occupational safety measures we seek
to avert dangers to individuals, and through good working conditions we promote and preserve the health and safety of our employees and of people whowork on our behalf.

and Safety

Occupational safety, however, is also part of the personal responsibility ofeach individual employee. Risks are to be avoided by means of foresighted,
careful and safety-conscious behavior. Any shortcomings in our occupationalsafety measures are to be reported to the responsible executive immediately.
We respect legitimate tenure rights as well as participation rights of local communities, in particular in our interactions with indigenous people as part of ourglobal business. In addition, we are committed to using security forces responsibly.

Unlawful Eviction or Seizure of Property, Use ofSecurity Forces

We have expressly committed ourselves to our particular responsibility forenvironmentally friendly transport and to environmental protection as a corporate value.

Environmental
Protection

We comply with all applicable environmental laws, regulations and standards.
In this respect, we particularly avoid harmful soil contamination, water pollution, air pollution, harmful noise emissions and excessive water consumption.
We comply with the Minamata Convention on Mercury, the Stockholm Convention on Persistent Organic Pollutants (POPs) and the Basel Convention
on the Control of Transboundary Movements of Hazardous Wastes and theirDisposal.
We are taking measures to combat climate change, adapt to climate change,build a full circular economy 3 and protect biodiversity and ecosystems. Especially, we are increasing energy efficiency as well as the use of renewableenergies and are reducing emissions, noise as well as our consumption ofmaterials and resources.

03 All employees are required to comply with the relevant regulations in force at
Conduct of all Employees
the DB Group.

Behavior in Public

The employees influence the public image of the DB Group. We will all behave
in a polite, courteous and service-minded manner to our customers and business partners at all times.

Confidentiality

All information about the business activities of the DB Group which has notbeen published and which is not public is treated as confidential. This includes
information about third parties, e.g. business partners, that is made available
3

In the Integrated Rail System („Systemverbund Bahn“).

to us as a result of our working for the DB Group. We will not use any
knowledge obtained from internal corporate processes for private gain.
Generally, all corporate and commercial communication with the media andthe general public is the responsibility of the Spokesperson of the Group(Head of Communications and Marketing, GN).
Avoiding Conflicts of Interest

We must avoid situations in which personal or individual financial interests
collide with the interests of the DB Group or of our business partners. In conflict situations, the interests of the DB Group must not be impaired. This does
not affect the compatibility of family and career.
Secondary occupations and investment in our competitors and/or business
partners must not introduce the risk of a conflict of interest. Any actual or suspected conflict of interest must be reported to the employee’s manager.
The DB Group encourages its employees to participate actively in society
in the form of public offices, clubs and associations or citizen’s groups, provided that such commitment is not in conflict with the legitimate interests ofthe DB Group.

Invitations and Gifts

It is permitted to accept and issue invitations associated with employment by
the DB Group in accordance with these guidelines, provided these are appropriate and not in anticipation of any improper benefits in return or any otherpreferential treatment.
The above also applies to the acceptance or granting of any gifts or otherconsiderations or advantages of any kind.

04 Partners

Conduct toward our Competitors, Public Officials and Business
The DB Group responds to the requirements of its customers, suppliers andbusiness partners and treats them honestly, responsibly and fairly.

Corruption

The DB Group will not condone corruption and unfair business practices by
employees or third parties commissioned by us. We do not offer, request oraccept, either directly or through third parties, any inducements, privileges
benefits or other advantages which could influence a person’s ability to makeobjective and fair business decisions.

Behavior towards

In general, all material and/or immaterial gifts of any kind whatsoever to publicofficials, employees or agents of public authorities or institutes or to the relatives of such persons are prohibited. Facilitation payments are prohibited.

Public Officials

Politics and PoliticalParties

Donations / Sponsoring

In general, gifts, entertainment and other advantages of any kind whatsoever
to political parties, their representatives, politicians or to holders of public offices or candidates for political offices are also prohibited.
The DB Group primarily funds measures in the fields of education, culture,integration and public welfare, climate and nature protection as well as humanitarian aid. The granting of any donations must always be transparent anddocumented. Donations may be made only on a voluntary basis and not in
anticipation of any consideration in return. In principle, we do not make political or religious donations.
Sponsoring measures must not serve any concealed promotion of interests.

Consultants / Agents /Brokers

Competition and Cartel
Laws

Embargoes, Sanctions,
Export and Import Controls
Supply chain, Shared
Responsibility with Business Partners

Any remuneration paid to consultants, agents and/or brokers must beappropriate to the services rendered and must not serve to provide business
partners or third parties with unfair advantage. Consultants, agents and/orbrokers are carefully selected and managed according to suitability criteriasuch as qualifications and integrity.
We abide by the applicable competition regulations and do not reach any arrangements or agreements which affect prices and/or terms and conditions
or which in any other way illegitimately restrict fair competition.
In our business activities, we ensure compliance with all applicable laws andregulations on the import and export of goods, services and information aswell as with the applicable embargoes and sanctions.
The DB Code of Conduct for Business Partners has been derived from theprinciples laid down in these Corporate Principles Ethics and we expect ourbusiness partners to comply with the principles specified in the DB Code ofConduct for Business Partners in their business dealings, and to make compliance with these principles mandatory for their own business partners.
Adherence to these principles is part of our shared responsibility. We will continue to develop our purchasing practices based on risk to incentivize sustainability and minimize our own contribution toward the root cause of identified
risks.

05 The activities of the DB Group are defined by responsibility and transparency
Responsibility to the Owners

vis-à-vis our owners. The objectives of our corporate work include the protection of the corporate assets and achieving a sustainable increase in the valueof the company.

Protection of CompanyAssets

In principle, company assets may only be used for company purposes andmust be treated with all due care.
Company property may neither be sold nor loaned to third parties nor usedfor non-company purposes, regardless of the condition or value of the property, without the explicit consent of the company.
All employees are required to act honestly, correctly and with integrity at all
times and to safeguard the Group's assets in the course of their work for theDB Group.
Fraud, corruption or any other criminal action will not be tolerated; suspected
wrongdoing will be investigated to the extent legally permitted in compliancewith data protection requirements and appropriate action taken if evidence ofsuch is discovered.

Reporting

All company reports and documents must be true and accurate in all material
respects and must conform with the applicable standards and contain fulldocumentation of all relevant information.

Insider Trading

Employees are not permitted to use any information which they receive in thecourse of their work for the DB Group and which is not in the public domain
in order to achieve financial or commercial benefits for themselves or for thirdparties.

We collect, process, and use personal data only insofar as permitted by therelevant laws and corporate directives.

Data Protection

Documents containing personal data about employees are treated as confidential, stored carefully and disclosed only to authorized persons.
The DB Group takes all necessary steps to prevent money laundering within
its sphere of influence.

Money Laundering

06 The DB Group shall implement the principles specified in this Code of ConCompliance with the Code of Conduct
duct in all business units worldwide.

All board members, managing directors, executives and employees of the DB
Group are obliged to comply with this Code of Conduct. The executives haveparticular responsibility for the communication and implementation of theseguidelines.

Obligation ofCompliance

All employees of the DB Group are required to report severe violations of thelaw that are likely to result in substantial damage to the DB Group or a Group
company through the DB Group’s whistleblowing system or to their supervisor.

Whistleblowing(internal and external)

Irrespective of this, risks relating to human rights and the environment andviolations of human rights- or environment-related duties at DB Group, itsGroup companies or in the supply chain can also be reported through thiswhistleblowing system.
The personal data of the employees of whom a report concerns are processedin accordance with the relevant laws and guidelines. More information is available at the above link.
We do not tolerate any retaliations against persons who report such infringements or against other persons covered by whistleblower protection.

Protection of theWhistleblower
Consequences

Any violation of the law and/or internal guidelines will lead to appropriate consequences for the employee responsible including prosecution under employment law or disciplinary consequences. Such infringements can also lead toprosecution under criminal and/or liability laws.

Further Information

Further information is available at www.db.de/compliance. In case of any
doubts or if you have any questions, please contact your manager. Alternatively, please do not hesitate to contact the Compliance department directly.

07 Resolved at the Management Board meeting of DB AG on November 7, 2023.
Effective Date

Effective as of January 1, 2024.

Regulation number 101.0105

Version 4.0

Valid forDB Group

Published by Deutsche Bahn AG

Coordination

Lutz Cauers (GC)

Phone: +49 30 297 62780